Justia Connecticut Supreme Court Opinion SummariesArticles Posted in Connecticut Supreme Court
Leonetti v. MacDermid, Inc.
Claimant suffered a lower back injury during the course of his employment and filed notice of a workers' compensation claim. Employer later informed Claimant he would be discharged from his employment. Claimant signed a termination agreement in order not to forfeit his severance pay. The agreement stipulated that Claimant released his previously accepted workers' compensation claim. The Workers' Compensation Commissioner refused to approve the termination agreement, finding there was no consideration offered by Employer to Claimant in exchange for Plaintiff's release of the workers' compensation clim. The Workers' Compensation Review Board affirmed. The Supreme Court affirmed, holding that the Board properly affirmed the Commissioner's decision not to approve the agreement as a "voluntary agreement" or stipulation in light of its finding that Claimant's release of his workers' compensation claim was not supported by consideration. View "Leonetti v. MacDermid, Inc." on Justia Law
Mirjavadi v. Vakilzadeh
Plaintiff filed for a divorce from Orang Fabriz, with whom she had a daughter. Defendant was hired to supervise visits between Fabriz and the child. During a visit supervised by Defendant at a shopping mall, Fabriz abducted the child and took her with him to Istanbul, Turkey. Plaintiff subsequently filed this negligence action against Defendant. The trial court found in favor of Defendant. The appellate court reversed and remanded for a new trial, concluding that the trial court engaged in a flawed analysis of causation and foreseeability and that the court made two clearly erroneous factual findings. The Supreme Court affirmed, holding that the appellate court correctly found the trial court's foreseeability analysis was fundamentally flawed. View "Mirjavadi v. Vakilzadeh" on Justia Law
Citibank, N.A. v. Lindland
This case arose when plaintiff initiated a foreclosure action against defendant. At issue on appeal was whether the trial court had authority to open a judgment of foreclosure by sale and related supplemental judgments after title had passed to the purchaser when a series of errors by the court and the parties caused the purchaser to buy a property that, unbeknownst to him but actually known by the second mortgagee, was in fact subject to a first mortgage that was to be foreclosed shortly thereafter. The court concluded that the appellate court incorrectly determined that the purchaser lacked standing under the circumstances of the present case; defendants inadequately briefed the issue of 17 Ridge Road, LLC's standing to intervene as a defendant and, therefore, the issue was deemed abandoned; and the appellate court correctly determined that the passing of title divested the trial court of jurisdiction to open the judgment of foreclosure by sale. Accordingly, the court reversed the judgment of the appellate court insofar as that court concluded that the trial court lacked authority to open the supplemental judgments. View "Citibank, N.A. v. Lindland" on Justia Law
Equity One, Inc. v. Shivers
Defendant executed a promissory note secured by a mortgage deed. Plaintiff subsequently sought to foreclose on the mortgage, claiming it was the holder of the note and mortgage. The trial court rendered a judgment of foreclosure by sale. Defendant filed an objection to the foreclosure, alleging that because he was no longer in default, Plaintiff did not have standing to foreclose the mortgage. Defendant also requested that the court direct Plaintiff to produce the original note to prove Plaintiff had standing to institute the foreclosure action. The court determined Plaintiff had standing and rendered judgment of strict foreclosure. The appellate court reversed, concluding that the trial court erred by failing to conduct an evidentiary hearing to determine whether Plaintiff had standing to bring this action after Defendant challenged Plaintiff's standing. The Supreme Court reversed, holding that, under the circumstances, Defendant failed to demonstrate that he was entitled to a full evidentiary hearing on the issue of Plaintiff's standing where the trial court's determination that Plaintiff had standing to commence this action was not in error. Remanded. View "Equity One, Inc. v. Shivers" on Justia Law
Chief Info. Officer v. Computers Plus Ctr., Inc.
This case arose from disputes between the Department of Information Technology and Defendant, a computer equipment supplier, over two contracts between the parties. The Department filed this action against Defendant, alleging breach of contract and fraud claims. Defendant filed an amended counterclaim, alleging takings and due process violations. The Department moved to dismiss the takings and due process claims based on the State's sovereign immunity. The trial court determined that the Department had waived the State's sovereign immunity regarding Defendant's counterclaims by bringing this cause of action against Defendant. After a jury trial, the trial court awarded Defendant damages on its procedural due process counterclaim. The Supreme Court (1) reversed the judgment of the trial court in favor of Defendant on the procedural due process counterclaim, holding that the Department did not waive the state's sovereign immunity by initiating the present litigation, and therefore, the trial court lacked subject matter jurisdiction over Defendant's counterclaims; and (2) affirmed in all other respects. View "Chief Info. Officer v. Computers Plus Ctr., Inc." on Justia Law
DiLieto v. County Obstetrics & Gynecology Group, P.C.
The named plaintiff, Michele DiLeito, commenced this medical malpractice action against Defendants. The jury found Defendants liable and awarded $5,200,000 plus interest to the substitute plaintiff, LiDeito's bankruptcy trustee. The Supreme Court affirmed except with respect to the amount of interest awarded. The trustee subsequently filed a motion for postjudgment interest pursuant to Conn. Gen. Stat. 37-3b. Thereafter, DiLieto was substituted as plaintiff. The trial court denied the motion, determining at DiLieto had failed to demonstrate Defendants wrongfully detained money payable to her under the judgment. DiLieto appealed, arguing that the trial court should not have applied the wrongful detention standard of Conn. Gen. Stat. 37-3a in declining to award postjudgment interest under section 37-3b. The Supreme Court reversed in part, holding that although the trial court properly determined that the same standard applies to an award of interest under section 37-3a as an award for interest under the version of section 37-3b in effect before the 1997 amendment, the standard the court actually applied was incorrect, as, under both provisions, a plaintiff who obtains a judgment is entitled to interest when the trial court determines under its discretion that such an award would be fair and equitable. Remanded. View "DiLieto v. County Obstetrics & Gynecology Group, P.C." on Justia Law
State v. Milner
After a jury trial, Defendant was convicted of burglary in the first degree. After Defendant was released from prison he was found to have violated the terms and conditions of his probation by engaging in criminal conduct. Accordingly, the trial court revoked Defendant's probation. Defendant appealed, claiming there was insufficient evidence to support the finding he had violated his probation. Before oral argument, however, Defendant pleaded guilty to the criminal charges upon which the finding rested. The appellate court subsequently dismissed as moot Defendant's appeal. Defendant appealed, arguing that his habeas corpus action collaterally attacking his criminal conviction revived the controversy such that mootness was averted. During the pendency of Defendant's appeal, the habeas court dismissed Defendant's habeas corpus action. The Supreme Court dismissed as moot Defendant's appeal, holding that dismissal of the habeas corpus action extinguished any claim to a live controversy in this appeal. View "State v. Milner" on Justia Law
State v. Acordia, Inc.
Defendant, an independent insurance broker, offered its clients insurance products from multiple insurance companies. Plaintiff, the State, brought this action against Defendant, alleging that Defendant's failure to disclose to its clients certain contingent commission agreements that it had entered into with the insurance companies violated the Connecticut Unfair Insurance Practices Act (CUIPA) and the Connecticut Unfair Trade Practices Act (CUTPA). The trial court rendered judgment in favor of Plaintiff. The Supreme Court reversed, holding (1) the trial court improperly concluded that Defendant violated CUIPA; and (2) in the absence of a CUIPA violation in this case, the CUTPA claim failed. View "State v. Acordia, Inc." on Justia Law
Inv. Assocs. v. Summit Assocs., Inc.
In 1991, Plaintiff commenced an action to recover on a promissory note. In 1992, Defendant, a guarantor of the note, moved from Connecticut to South Carolina. In 1994, the trial court rendered judgment in Plaintiff's favor. In 2007, Plaintiff commenced an action in Connecticut against Defendant to enforce the judgment. The trial court dismissed the action for lack of personal jurisdiction, concluding that Defendant's contact with Connecticut was insufficient to satisfy the requirements of either the long arm statute or due process. In 2009, the Legislature enacted Conn. Stat. 52-598(c), a mechanism whereby a judgment creditor can "revive" an unsatisfied judgment for money damages before the period for enforcement expires. Plaintiff subsequently filed a motion to revive the 1994 judgment. The trial granted the motion. The appellate court affirmed. The Supreme Court affirmed, holding that the appellate court properly determined that (1) Defendant's challenge to the trial court's subject matter jurisdiction on appeal was barred as an improper collateral attack on the original judgment; and (2) section 52-598(c) applies retroactively and provides a proper basis for the trial court's jurisdiction over Defendant for purposes of adjudicating the motion to revive. View "Inv. Assocs. v. Summit Assocs., Inc." on Justia Law
Town of Marlborough v. AFSCME, Council 4, Local 818-052
The Town of Malborough terminated the employment of Emily Chaponis as town assessor after the board of selectmen did not make a motion to reappoint her to a successive term of office. Chaponis filed a grievance through the Union, of which she was a member, alleging that the Town violated its collective bargaining agreement with the Union by discharging her without just cause. An arbitration panel ordered the Town to reinstate Chaponis to her position, concluding that the Town violated the agreement when it terminated Chaponis' employment without just cause. The trial court denied the Town's application to vacate the arbitration award. The Supreme Court reversed, holding that the arbitrators' award ordering the reinstatement of Chaponis' employment after the statutory expiration of her term of office contravened the mandates of the statutory scheme governing the term of office for municipal officers, and therefore, the award was unenforceable. Remanded. View "Town of Marlborough v. AFSCME, Council 4, Local 818-052" on Justia Law